Tag Archives: Fees for Technical Services

Payments for global telecommunication facility not “ fees for technical services ”

By | March 14, 2017

Payments for global telecommunication facility not “fees for technical services” The Supreme Court of India held that payments received by a Danish shipping company for its global telecommunication system (payments from Indian agents) were reimbursements in nature. Because no profit element was embedded in these payments and also because the foreign company had not provided any technical… Read More »

Management support services not fees for technical services under tax treaty with Finland

By | November 3, 2016

Management support services not “fees for technical services” under tax treaty with Finland  The Kolkata Bench of the Income-tax Appellate Tribunal held that no technology, know-how, or skills were made available by the taxpayer while rendering management support and other services to enable the Indian group company to function on its own without the taxpayer.… Read More »

Mere availing of services of non resident company for global market survey is not fees for Technical Services hence not TDS

By | November 2, 2015

Mere availing of services of non-resident company for global market survey to determine business prospects to carry out project in India is not ‘ Fees for Technical Services’ under India UK Treaty Income Tax Officer v. Skill Infrastructure Ltd.,  [ITAT Mum.] ITA No. 865-867 of 2011 Date of Decision:  July 29, 2015 Facts of the… Read More »